Summer is coming to a close and soon the school year will be in full swing. A new school year means new opportunities and new challenges. If you have a child who has a learning disability or behavioral challenges, then you recognize the stress that can come along with a new school year. Before the halls are full of the hustle and bustle of students, I’d like to take a few minutes to review New Hampshire’s Medicaid to Schools Program and provide some resources for school districts and SAUs that are currently receiving or are interested in receiving Medicaid reimbursement for behavior analytic services.
Behavior Analysts are credentialed and overseen by the Behavior Analysis Certification Board (BACB). Certified Behavior Analysts hold the credential “BCBA” which stands for Board Certified Behavior Analyst. While some states also offer licensing for Behavior Analysts (MA being one very close to home), New Hampshire does not currently license Behavior Analysts who are practicing in the state. Because the Medicaid to School Program in NH requires that practitioners providing reimbursable services be licensed in the state, Mental Health Services (including behavior management and support) do not meet these requirements when rendered by BCBAs (See New Hampshire’s “Medicaid to Schools” Program A Snapshot Summary* prepared by MSB™ for additional information).
However, as the number of BCBAs in the state has risen and as schools have begun to understand the need for the services they provide, some school districts have sought waivers for behavior analytic services that allow for Medicaid reimbursement. For more information on obtaining a waiver check out, New Hampshire Medicaid to Schools Regulations (effective 8/23/16).
Once a waiver has been obtained, reimbursement for behavior analytic services is not guaranteed. In fact, school districts are expected to maintain strict documentation in order to receive reimbursement not only for behavior analytic services, but for all Medicaid reimbursable services. MSB recently published a list of the top 10 reasons that school districts are unable to recoup Medicaid reimbursement.
Services that are billed have not been “ordered” in IEPs.
Medicaid will only reimburse for services that have been included in a student’s Individualized Education Plan (IEP). So if a waiver has been obtained, reimbursement will only be available for behavior analytic services that have been ordered in a student’s IEP service delivery grid.
2. Covered services are not billed to Medicaid. Services that have been written into IEPs need to be billed to Medicaid in order to be reimbursed. If providers are not submitting claims, the district will not receive reimbursement.
3. Orders, recommendations, or referrals are not signed by qualified professionals. Medicaid requires that qualified providers sign off on all services that are recommended for a student. This form is usually presented at the IEP meeting in the presence of the student’s IEP team. Without the order for the service being signed, Medicaid will not reimburse services.
4. Transaction logs (service records) do not have original, handwritten signatures. Providers are required to sign off on all services that have been rendered. If the provider does not ensure a signature for all services, appointments/sessions without one will not be reimbursed. Electronic billing systems such as LUMEA have made this easier for many districts.
5. Rehabilitative Assistants’ transaction logs are not signed by a qualified practitioner, AND/OR there is no documentation of weekly consultation between the assistant and the practitioner. Rehabilitative Assistants work under the supervision of a qualified practitioner. In order for rehab services to be reimbursed, both parties must sign off AND document their consultation.
6. Covered services are being provided by unqualified professionals. As previously mentioned, Medicaid requires specific licensing /credentialing in order to reimburse services. For more information, see “Medicaid to Schools” Program rules.
7. Out of District services are not ordered in IEPs. When a student is placed Out of District, the Out of District Placement must follow all Medicaid to School Program rules in order to be eligible for reimbursement.
8. Districts bill for non-school days. Medicaid reimbursable services cannot be rendered on non-school days. Most services require face time with the student and are therefore not able to be delivered on weekends, holidays, snow days, etc.
9. Services are not ordered, but rather allowed. Only services that have been ordered (included in a student’s service delivery grid and prescribed for a certain amount of time) will be reimbursed by Medicaid. If the team includes language such as “Student may receive behavior support up to 5 hrs per year” these services will not be reimbursed. 10. Orders for assessments are not being included in IEPs. Assessments and evaluations are reimbursable. Meeting and adding these into a student’s IEP allows for time spent on assessments to be submitted for reimbursement. For additional information about Medicaid denials visit, http://msb-services.com/new-hampshire-resources/new-hampshire-guidance/top-10-audit-findings/ I hope this information helps you as you prepare for the 2017-2018 school year. In addition to all of the resources included throughout, the Department of Education (DOE) is also a great resource on this topic. Thanks so much for reading, and take care!